Keller v. Commissioner’s Empirical Analysis
1984
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 36 later decisions — most recently December 2016 · most notably Tolwinsky v. Commissioner (1986), Prabel v. Commissioner (1988)
9 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 26 U.S.C. § 162 · 26 U.S.C. § 263 (Interest Equalization Tax Act) · 26 U.S.C. § 446
Relies on United States v. United States Gypsum Co. · Pullman-Standard v. Swint · Automobile Club of Mich. v. Commissioner · Dixon v. Unied States · Commissioner v. Hansen
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]hile they are entitled to some evidentiary weight, the Commissioner's private letter rulings and Revenue Rulings are not controlling authority and do not persuade this court in the present case.”
2 later decisions quote this exact passage · from the majority“SEC. 446(b). Exception. — If no method of accounting has been regularly used by the taxpayer, or if the method used does not clearly reflect income, the computation of taxable income shall be made under such method as, in the opinion of the Secretary, does clearly reflect income.”
1 later decision quote this exact passage · from the majority“"There is clearly no common thread or governing principle which rationalizes and renders predictable the results concerning deductibility of advance payments in general.” [Quoting from Mann v. Commissioner, 483 F.2d 673, 676 (8th Cir. 1973).]”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.